- 8 - hearing only if the person did not receive a notice of deficiency for the taxes in question or did not otherwise have an earlier opportunity to dispute the tax liability. See Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, supra. Section 6330(d) provides for judicial review of the administrative determination in either the Tax Court or Federal District Court. Petitioner challenges the existence of the asserted tax liabilities for 1995 and 1996 on the grounds that she did not receive income from a taxable source and respondent failed to demonstrate that she is liable for Federal income taxes. Although respondent determined that the income in question is attributable to taxable wages, petitioner never identified the alleged nontaxable source of the income, nor did she expressly deny receiving the wages in question. The record shows that Appeals Officer Johnson gave petitioner every opportunity to produce documentation in support of her position. Petitioner’s arguments that she is not subject to Federal income taxes and that she did not earn taxable income during 1995 and 1996 are frivolous and groundless. Goza v. Commissioner, supra. As the Court of Appeals for the Fifth Circuit has remarked: “We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do soPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011